L'Oreal India Private Limited - GARNIER BLACK NATURALS

Recommendation: Upheld | Medium: Suo Motu - NAMS (TAMS)

The CCC-R Decision The CCC-R panel reviewed the advertiser’s claim of “India's most trusted hair colour”, which was previously found to be inadequately substantiated. The original concern was that the supporting TRA study lacked key methodological details, and appeared to measure brand salience more than brand trust. In their submission for review, the advertiser provided additional documents including the full TRA questionnaire, an updated 2025 methodology note, and a written clarification from TRA on their research methodology. The advertiser explained that the study focused on urban peer influencers - salaried males, salaried females, and home influencers residing in large apartment complexes across top metropolitan cities. The CCC-R panel observed that this sampling method excluded a wide range of consumer groups particularly those from smaller towns, rural areas, and lower socio-economic segments who form a significant portion of the actual user base for hair colour products. Furthermore, the study did not include other influential consumer segments such as educators, celebrities, product-specific experts like dermatologists and beauty advisors. Their exclusion further limited the scope of the research. During the discussion, the CCC-R panel raised additional concerns. The advertiser confirmed that there was no data available showing the number of respondents per product category, including hair colour. They did not have specific data on how many male and female participants used or commented on hair colour products, nor was there any monitoring of gender representation within the sample. When questioned about whether urban peer influencers could affect opinions in rural areas, the advertiser referred to TRA’s explanation that rural consumers may not be aware of brand trust efforts or able to recall many brands as required by the survey. However, the CCC-R panel found this reasoning inadequate. Given the nationwide nature of the claim, the CCC-R panel emphasized that the study should represent consumers from across the country. With regard to the IRP decision of 2017, the CCC-R panel noted that the facts of that case were different. The advertiser in that instance operated in a distinct category, unlike an FMCG hair colour brand. Therefore, the earlier decision need not be treated as a precedent for accepting the current brand trust study. Based on the review submissions and the detailed discussions, the CCC-R panel concluded that the claim, “India’s most trusted hair colour”, was inadequately substantiated as the study lacked a representative sample, excluded key consumer segments, and did not provide category and gender specific data. The claim is misleading by exaggeration and is likely to cause widespread disappointment in the minds of consumers. The said claim contravened Chapter I, Clauses 1.1, 1.4 and 1.5 of the ASCI Code. The earlier decision of complaint being Upheld stands on Review.